What changed
The UNSC removed two entries from its ISIL (Da'esh) & Al-Qaida Sanctions List: Said ben Abdelhakim ben Omar al-Cherif and Emrah Erdogan. RBI has advised all regulated entities to take note of this deletion and ensure compliance with the updated list.
What it means for you
Banks and lenders must immediately update their AML/KYC screening systems to remove these two individuals from their watchlists. This ensures that frozen accounts or restrictions on these persons are lifted in line with UNSC directives. Failure to update could lead to compliance gaps or customer grievances.
What you must do
- Update your AML screening databases to remove the two delisted individuals from sanctions watchlists.
- Review any accounts or transactions previously frozen due to these entries and take appropriate action as per RBI guidelines.
- Ensure internal compliance teams are aware of the UNSC press release and the updated sanctions list available on UN website.
- Forward any delisting requests received from customers to Joint Secretary (CTCR), MHA as per MHA instructions.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Other RBI-regulated entities
What is the basis for this RBI circular?
It is issued under Section 51A of the Unlawful Activities (Prevention) Act, 1967, and references the Master Direction on KYC dated February 25, 2016 (as amended). The UNSC removed two entries from its sanctions list via press release SC/14440 dated February 19, 2021.
How should we handle accounts of the delisted individuals?
You must update your screening systems to remove these names from watchlists. Any accounts or assets frozen solely due to these entries should be unfrozen, subject to other legal obligations. Ensure compliance with RBI's KYC master direction.
Where can we find the updated UNSC sanctions list?
The updated list is available at www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list. The UNSC press release and details on delisting procedures are also linked in the RBI circular.